Interpretation Response #22-0045

Interpretation Response Details

August 24, 2022

Mr. Erik Steinbeck, CDGP
Global Logistics Manager
Parker Hannifin Corporation
Engineered Materials Group
601 South Street
Saegertown, PA  16433

Reference No. 22-0045

Dear Mr. Steinbeck:

This letter is in response to your April 21, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of an electro hydrostatic actuation (EHA) system. In your email, you state that your company designs and manufactures EHA systems that are power-by-wire actuation systems, which utilize aircraft electric power for flight control surface actuation. You also state that the EHA system is charged with between 200 and 400 pounds per square inch (psig) of nitrogen prior to shipment, has a minimum burst pressure approximately 20 times the charge pressure at 70 °F, and is transported as "UN3164, Articles, pressurized pneumatic or hydraulic containing non-flammable gas, 2.2." You ask whether the EHA system—as described and pictured in your email-would qualify for the limited quantity exceptions for accumulators, as specified in § 173.306(f)(1).

As specified in § 173.22 of the HMR, it is the responsibility of the shipper to properly classify a hazardous material that is to be offered for transportation and ensure that it is shipped in an authorized packaging. Based on the information you provided in your email, it appears that your component meets the burst pressure requirements for accumulators in § 173.306(f)(1). However, § 173.306(f)(1) is meant for an accumulator which is installed in a motor vehicle, construction equipment, or assembled machinery-not a stand-alone component, such as your electro hydrostatic actuator. Furthermore, insufficient information is provided to classify your component as an accumulator, as recognized by § 173.306(f).

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.22, 173.306(f), 173.306(f)(1)

Regulation Sections